Snow v. State

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Questions Presented

1. Whether the State's use of all eight of its peremptory challenges against African-American venirepersons violated Batson v. Kentucky.
2. Whether the Court should abolish peremptory challenges as unconstitutional when the issue was raised for the first time on appeal.
3. Whether an emotional outburst by victims' family members during closing argument required a mistrial.
4. Whether a jury note expressing concern for its safety showed improper bias or consideration of extraneous information during sentencing.
5. Whether alleged outside contact involving a juror required a new trial.
6. Whether the trial court properly determined that Snow was competent to stand trial.
7. Whether the trial court improperly admitted a photograph of the victims and patrol vehicle.
8. Whether charging Snow as a habitual offender barred the State from seeking the death penalty under double-jeopardy principles.
9. Whether the evidence supported submission of the statutory great-risk-of-death aggravating circumstance.
10. Whether Snow was denied effective assistance of counsel when the trial court refused appointed counsel's requests to withdraw.
11. Whether statements Snow made to law-enforcement officers were obtained in violation of Miranda and the right to counsel.
12. Whether Mississippi's death-penalty statutes were unconstitutional as cruel and unusual punishment.
13. Whether the death sentences were excessive or disproportionate under Mississippi's statutory proportionality review.

Holdings

1. The State's eight peremptory strikes against African-American venirepersons did not establish purposeful racial discrimination because the State provided race-neutral reasons and the trial court adequately investigated and accepted those reasons.
2. Snow's request to abolish peremptory challenges was procedurally barred because he did not raise it at trial, and the Court declined to consider the issue for the first time on appeal.
3. The trial court did not abuse its discretion by denying a mistrial after an emotional outburst during closing argument because the court removed the jury, restored order, admonished the jury, and obtained assurances that the jurors could disregard the incident.
4. The jury's note expressing concern for its safety and the alleged contact involving a juror did not require a mistrial or new trial because the record did not establish that the jury considered improper outside information or influence.
5. The trial court properly found Snow competent to stand trial, and the finding was supported by the evidence and was not clearly erroneous or against the overwhelming weight of the evidence.
6. The trial court did not abuse its discretion by admitting State's Exhibit 33 because the photograph had probative value in showing the position of the vehicle and victims and was not so gruesome or inflammatory as to require reversal.
7. Charging Snow as a habitual offender did not bar the State from seeking the death penalty and did not create a double-jeopardy violation.
8. The evidence supported submitting the aggravating circumstance that Snow knowingly created a great risk of death to many persons.
9. Snow was not denied effective assistance of counsel when the trial court denied counsel's motions to withdraw and appointed additional counsel.
10. Snow's statement that shooting the deputies was a stupid thing to do was admissible because, under the totality of the circumstances, Snow voluntarily, knowingly, and intelligently waived his Miranda rights; the trial court did not clearly err in finding that the officer's conduct was not interrogation as to Snow's initial statement.
11. The Court did not decide whether Snow's response concerning the location of his clothes was admissible because the statement itself was not introduced at trial; the Court nevertheless held that the trial court did not err in finding Snow's initial volunteered statement voluntary.
12. The Court rejected Snow's facial constitutional challenge to Mississippi's death penalty and held that his death sentences were neither excessive nor disproportionate to the sentences imposed in similar cases.

Key quotations

Factual background

While being transported from the Jefferson Davis County Jail to the Mississippi Department of Corrections, Snow shot Deputies Tommy Bourne and J.P. Rutland from the back seat of a moving patrol vehicle. Snow then climbed through the front window, attempted to control the moving vehicle, and fired additional shots before fleeing. He was apprehended later that day. A jury convicted him of two counts of capital murder and escape, found him to be a habitual offender, and imposed death sentences for the murders.

Procedural history

A Simpson County grand jury indicted Snow for two counts of capital murder and escape as a habitual offender. Venue was transferred first to Lauderdale County and ultimately to Lowndes County. After a jury convicted Snow and imposed two death sentences, the trial court denied his posttrial motions. Snow timely appealed to the Mississippi Supreme Court, which affirmed all convictions and sentences.